Fully compliant with Safe Harbor.

Our firm is wholly committed to protecting the privacy of our clients’ company data and personal information. As such, we are in compliance with the US-EU Safe Harbor Framework in regards to the transfer of personal data from the European Union member countries to the United States. CFGI certifies that we adhere to all principles of the Safe Harbor Framework. For further information on the US-EU Safe Harbor policy, please visit the US Department of Commerce website at:

www.export.gov/safeharbor

Privacy Principles

CFGI abides by these principles when handling personal data received from the EU member countries. They are based on the seven Safe Harbor Principles.

Notice

If CFGI obtains personal data from our EU clients, we will notify the individuals to whom the information relates about the purpose for which we use the data, and provide them with the relevant contact information should they have inquires or complaints.

Choice

CFGI will give individuals the opportunity to choose (opt out) whether their personal information will be disclosed to an unrelated third party or used for a purpose other than that for which it was originally collected or subsequently authorized by the individual. For sensitive information, affirmative or explicit (opt in) choice must be given if the information is to be disclosed to a third party or used for a purpose other than its original purpose or the purpose authorized subsequently by the individual.

Onward Transfer (Transfers to Third Parties)

To disclose information to an unrelated third party, CFGI will also apply the notice and choice principles. If CFGI transfers information to a third party that is acting as an agent, we will ensure that it subscribes to the Safe Harbor Principles or is subject to the Directive or another adequacy finding. Alternatively, the CFGI will agree in writing with such third party requiring that the third party provide at least the same level of privacy protection as is required by the relevant principles.

Access

Individuals will be provided their personal information about them upon request to CFGI. They will also be allowed to correct, amend, or delete that information where it is inaccurate or incomplete.

Security

CFGI will make reasonable efforts to prevent personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Data Integrity

CFGI will only use personal information that is relevant for the purposes for which it is collected. CFGI will take reasonable steps to ensure that data is reliable for its intended use, accurate, complete, and current.

Enforcement

Individuals may contact CFGI with inquiries, requests, or complaints by the following methods:

Mail: CFGI, 99 High Street, 30th Floor, Boston, Massachusetts, 20110

Email: sewer@cfgi.com

In the event that a dispute cannot be resolved between CFGI and the individual, he or she may contact:

JAMS

http://www.jamsadr.com/